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HomeMy WebLinkAbout07-1259 KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY 1.0. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff FRANK PRETOPAPA, Plaintiff, vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. cJ1- /~SCJ ~ ~ BRANDY RITTLE, Defendant. : CIVIL ACTION - LAW : IN CUSTODY CUSTODY COMPLAINT 1. The Plaintiff is Frank Pretopapa, residing at 138 Peach Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Brandy Rittle, whose current residence is unknown. As of the morning of March 7, 2007, Defendant was residing at 138 Peach Lane, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks full physical and sole legal custody of the following male child: NAME Mason Pretopapa PRESENT RESIDENCE 138 Peach Lane Carlisle, PA 17013 AGE 2 years D.O.B. 10/28/2004 4. Mason Pretopapa (hereinafter the "child") was born out of wedlock. 5. The child is presently in the custody of Plaintiff, whose residence is unknown. As of the morning of March 7, 2007, the child was residing with Defendant and Plaintiff at 138 Peach Lane, Carlisle, Cumberland County, Pennsylvania. 6. Since his birth, the child has resided with the following persons and at the following addresses: PERSONS ADDRESSES DATES Frank Pretopapa Brandy Rittle 138 Peach Lane Carlisle, PA 17013 March 13, 2006 - Present Frank Pretopapa 76 Cold Springs Road Brandy Rittle Carlisle, PA 17015 Debra Kraft (paternal grandmother) Steve Kraft (paternal grandfather) Birth - March 13, 2006 7. The mother of the child is Brandy Rittle, whose current residence is unknown. As of the morning of March 7, 2007, she was residing at 138 Peach Lane, Carlisle, Cumberland County, Pennsylvania. It is believed she may be staying temporarily with her mother and her mother's boyfriend in Harrisburg. She is single. 8. The father of the child is Frank Pretopapa, currently residing at 138 Peach Lane, Carlisle, Cumberland County, Pennsylvania. He is single. 9. The relationship of Plaintiff to the child is that of Father. As of the morning of March 7, 2007, the Plaintiff resided with Defendant and the child. At this time, Plaintiff resides alone. 10. The relationship of Defendant to the child is that of Mother. As of the morning of March 7, 2007, the Defendant resided with Plaintiff and the child. At this time, it is unknown where or with whom Defendant currently resides. 11. Plaintiff has not participated as a party in previous litigation concerning the custody of the child. 12. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. 13. The morning of March 7, 2007, Defendant informed Plaintiff that she was going to pay the rent, and then take the child to McDonalds. Defendant instead took the rent money, cleaned out the rest of parties' account, and left with the child. 14. Since Defendant lied to Plaintiff and absconded with the child, Defendant has since informed Plaintiff that she has left him and that he will never see the child again. As a result of Defendant's statement, Plaintiff is uncertain what Defendant will do with herself and the child. 15. Plaintiff does not know where or with whom Defendant and/or the child is living, if Defendant is in fact living with the child, nor If Defendant will stay in the city, county and/or state. 16. Prior to Defendant's leaving, Plaintiff was the primary caregiver of the child. As such, Plaintiff has tended to the child during both the day and night, since the child's birth, taking care of the child. 17. Defendant has been diagnosed with bipolar disorder and epilepsy. Defendant regularly fails to take her prescribed medication. 18. By failing to take her prescribed medication, and as a result of her conditions, Defendant is an inadequate parent with whom the child is in danger. By way of example, Defendant has in fact passed out while giving the child a bath, putting the child in danger of drowning. 19. Defendant did not get Plaintiff's consent to take the child. Defendant was only able to abscond with the child through deception, specifically, by lying to Plaintiff and telling him she was simply taking the child to McDonald's. Plaintiff has not told Defendant where she will be living. 20. Plaintiff does not have a substantial employment history that would act to anchor Plaintiff to the area. Specifically, Plaintiff just began a new job this week. As such, Defendant does not know that he will be able to find her or the child. 21. Plaintiff would never have voluntarily agreed to allow Defendant to move their minor child out of the home. Defendant is trying to usurp Plaintiff's parental rights by making a unilateral decision concerning their child. 22. Plaintiff will be filing an Emergency Petition for Special Relief with this Honorable Court respectfully requesting that this Court issue an Order that mandates that Defendant return the child to his home and primary caregiver. 23. The best interest and permanent welfare of the child will be served by the granting relief requested because: (a) The child's emotional and physical well-being will be continued if he maintains a loving and consistent relationship with the Plaintiff, who has been the primary caregiver of the child since birth. (b) Plaintiff is able to provide a stable home and emotional environment for the child; (c) Defendant is not only moving the child out his home with father, but has stated that Plaintiff and Plaintiffs family will never see the child again. Such an action would keep the child away from the family members with whom he has had constant contact. This could cause the child to suffer immediate and irreparable harm; (d) Defendant is moving the child into a situation that could be extremely dangerous. Defendant has been diagnosed with bipolar disorder and epilepsy, and regularly fails to take her prescribed medication. As such, Defendant's mental and physical state make her a danger to the child, and her decisions regarding the child less than reasonable; and (e) Plaintiff has the facilities to provide for the care, comfort and control of the child, as well as the intention and desire to do so. WHEREFORE, Plaintiff requests that this Honorable Court grant the following relief: (a) Award Plaintiff full physical and sole legal custody of the child. Respectfully Submitted, Dated: ~(7/ a 7 KOPE & ASSOCIATES, LLC By:~L esle. . B am, Esq. VERIFICATION I, Frank Pretopapa, verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. s. 9 4904 relating to unsworn falsification to authorities. Dated: 3 -- / - 0; {~~ Frank Pretopapa, Plaintiff -r~ ~ u.> ~ "'0 ~ ~ ...Q 't-' ~ r '"' --.. 5L-> '6 o c s: (I-~ ;-:: -.-l -< N = = -J :r. ;;;;.... :xl I CO ~ ~- o -n :r-n fllr::; -O'::!:..' -4l j /< r ~_::'~ L~~) -.1.- - , : s~~s ;-~rn ;. ) ;:::1 -..~ 5"J -< ~I o r"":l KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeama:D.kopelaw.com Attorney for Plaintiff FRANK PRETOPAPA, Plaintiff, vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6 7- J~SC; ~ I..u-. BRANDY RITTLE, Defendant. CIVIL ACTION - LAW : IN CUSTODY EMERGENCY PETITION FOR SPECIAL RELIEF 1. The Plaintiff is Frank Pretopapa, residing at 138 Peach Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Brandy Rittle, whose current residence is unknown. As of the morning of March 7, 2007, Defendant was residing at 138 Peach Lane, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff has filed for full physical and sole legal custody of the male child, Mason Pretopapa, whose date of birth is October 28,2004, is currently 2 years old, and as of March 7, 2007, was residing with Plaintiff and Defendant at 138 Peach Lance, Carlisle, Cumberland County, PA 17013. Refer to the Custody Complaint attached herein as Exhibit "A". 4. Mason Pretopapa (hereinafter "child") was born out of wedlock. 5. Up to this time the parties have not had need for a custody order as they have been raising the child together, with Plaintiff acting as the primary caregiver. 6. Immediately prior hereto, a Custody Complaint was filed with the Court, but as such, a custody determination has yet to be made. See Exhibit A. 7. The morning of March 7, 2007, Defendant informed Plaintiff that she was going to pay the rent, and then take the child to McDonalds. Defendant instead took the rent money, cleaned out the remainder of the parties' account, and left with the child. B. Since Defendant lied to Plaintiff and absconded with the child, Defendant has since informed Plaintiff that she has left him and that he will never see the child again. As a result of Defendant's statement, Plaintiff is uncertain what Defendant will do with herself and the child. 9. Plaintiff does not know where or with whom Defendant and/or the child is living, if Defendant is in fact living with the child, nor If Defendant will stay in the city, county and/or state. 10. Prior to Defendant's leaving, Plaintiff was the primary caregiver of the child. As such, Plaintiff has tended to the child during both the day and night, since the child's birth, taking care of the child. 11. Defendant has been diagnosed with bipolar disorder and epilepsy. Defendant regularly fails to take her prescribed medication. 12. By failing to take her prescribed medication, and as a result of her conditions, Defendant is an inadequate parent with whom the child is in danger. By way of example, Defendant has in fact passed out while giving the child a bath, putting the child in danger of drowning. 13. Defendant did not get Plaintiff's consent to take the child. Defendant was only able to abscond with the child through deception, specifically, by lying to Plaintiff and telling him she was simply taking the child to McDonald's. Plaintiff has not told Defendant where she will be living. 14. Plaintiff does not have a substantial employment history that would act to anchor Plaintiff to the area. Specifically, Plaintiff just began a new job this past week. As such, Defendant does not know that he will be able to find her or the child. 15. Plaintiff would never have voluntarily agreed to allow Defendant to move their minor child out of the home. Defendant is trying to usurp Plaintiff's parental rights by making a unilateral decision concerning their child. 16. Plaintiff is respectfully requesting that this Honorable Court issue an Emergency Order awarding physical custody of the child to Plaintiff, pending a Conciliation Conference in this matter. 17. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The child's emotional and physical well-being will be continued if he maintains a loving and consistent relationship with the Plaintiff, who has been the primary caregiver of the child since birth. (b) Plaintiff is able to provide a stable home and emotional environment for the child; (c) Defendant is not only moving the child out his home with father, but has stated that Plaintiff and Plaintiff's family will never see the child again. Such an action would keep the child away from the family members with whom he has had constant contact. This would cause the child to suffer immediate and irreparable harm; (d) Defendant is moving the child into a situation that could be extremely dangerous. Defendant has been diagnosed with bipolar disorder and epilepsy, and regularly fails to take her prescribed medication. As such, Defendant's mental and physical state make her a danger to the child, and her decisions regarding the child less than reasonable; and (e) Plaintiff has the facilities to provide for the care, comfort and control of the child, as well as the intention and desire to do so. WHEREFORE, Plaintiff requests that this Honorable Court grant the following relief: (a) Removal of the child from the custody of the Defendant into the care of the Plaintiff pending a pre-hearing conciliation conference in this matter. Respectfully Submitted, Dated: 'J:J -7 - ~ 007 VERIFICATION I, Frank Pretopapa, verify that the statements made in this Emergency Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. s. 9 4904 relating to unsworn falsification to authorities. Dated: 3 --- '7,- (J / ~~~ Frank Pretopapa, Plaintiff KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY J.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff vs. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. FRANK PRETOPAPA, Plaintiff, BRANDY RITTLE, Defendant. : CIVIL ACTION - LAW : IN CUSTODY CUSTODY COMPLAINT 1. The Plaintiff is Frank Pretopapa, residing at 138 Peach Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Brandy Rittle, whose current residence is unknown. As of the morning of March 7, 2007, Defendant was residing at 138 Peach Lane, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks full physical and sole legal custody of the following male child: NAME Mason Pretopapa PRESENT RESIDENCE 138 Peach Lane Carlisle, PA 17013 AGE 2 years D.O.B. 10/28/2004 4. Mason Pretopapa (hereinafter the "child") was born out of wedlock. 5. The child is presently in the custody of Plaintiff, whose residence is unknown. As of the morning of March 7, 2007, the child was residing with Defendant and Plaintiff at 138 Peach Lane, Carlisle, Cumberland County, Pennsylvania. ~ EXHIBIT ~ A I 6. Since his birth, the child has resided with the following persons and at the following addresses: PERSONS ADDRESSES DATES Frank Pretopapa Brandy Rittle 138 Peach Lane Carlisle, PA 17013 March 13, 2006 - Present Frank Pretopapa 76 Cold Springs Road Brandy Rittle Carlisle, PA 17015 Debra Kraft (paternal grandmother) Steve Kraft (paternal grandfather) Birth - March 13, 2006 7. The mother of the child is Brandy Rittle, whose current residence is unknown. As of the morning of March 7, 2007, she was residing at 138 Peach Lane, Carlisle, Cumberland County, Pennsylvania. It is believed she may be staying temporarily with her mother and her mother's boyfriend in Harrisburg. She is single. 8. The father of the child is Frank Pretopapa, currently residing at 138 Peach Lane, Carlisle, Cumberland County, Pennsylvania. He is single. 9. The relationship of Plaintiff to the child is that of Father. As of the morning of March 7, 2007, the Plaintiff resided with Defendant and the child. At this time, Plaintiff resides alone. 10. The relationship of Defendant to the child is that of Mother. As of the morning of March 7, 2007, the Defendant resided with Plaintiff and the child. At this time, it is unknown where or with whom Defendant currently resides. 11. Plaintiff has not participated as a party in previous litigation concerning the custody of the child. 12. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. 13. The morning of March 7, 2007, Defendant informed Plaintiff that she was going to pay the rent, and then take the child to McDonalds. Defendant instead took the rent money, cleaned out the rest of parties' account, and left with the child. 14. Since Defendant lied to Plaintiff and absconded with the child, Defendant has since informed Plaintiff that she has left him and that he will never see the child again. As a result of Defendant's statement, Plaintiff is uncertain what Defendant will do with herself and the child. 15. Plaintiff does not know where or with whom Defendant and/or the child is living, if Defendant is in fact living with the child, nor If Defendant will stay in the city, county and/or state. 16. Prior to Defendant's leaving, Plaintiff was the primary caregiver of the child. As such, Plaintiff has tended to the child during both the day and night, since the child's birth, taking care of the child. 17. Defendant has been diagnosed with bipolar disorder and epilepsy. Defendant regularly fails to take her prescribed medication. 18. By failing to take her prescribed medication, and as a result of her conditions, Defendant is an inadequate parent with whom the child is in danger. By way of example, Defendant has in fact passed out while giving the child a bath, putting the child in danger of drowning. 19. Defendant did not get Plaintiff's consent to take the child. Defendant was only able to abscond with the child through deception, specifically, by lying to Plaintiff and telling him she was simply taking the child to McDonald's. Plaintiff has not told Defendant where she will be living. 20. Plaintiff does not have a substantial employment history that would act to anchor Plaintiff to the area. Specifically, Plaintiff just began a new job this week. As such, Defendant does not know that he will be able to find her or the child. 21. Plaintiff would never have voluntarily agreed to allow Defendant to move their minor child out of the home. Defendant is trying to usurp Plaintiff's parental rights by making a unilateral decision concerning their child. 22. Plaintiff will be filing an Emergency Petition for Special Relief with this Honorable Court respectfully requesting that this Court issue an Order that mandates that Defendant return the child to his home and primary caregiver. 23. The best interest and permanent welfare of the child will be served by the granting relief requested because: (a) The child's emotional and physical well-being will be continued if he maintains a loving and consistent relationship with the Plaintiff, who has been the primary caregiver of the child since birth. (b) Plaintiff is able to provide a stable home and emotional environment for the child; (c) Defendant is not only moving the child out his home with father, but has stated that Plaintiff and Plaintiff's family will never see the child again. Such an action would keep the child away from the family members with whom he has had constant contact. This could cause the child to suffer immediate and irreparable harm; (d) Defendant is moving the child into a situation that could be extremely dangerous. Defendant has been diagnosed with bipolar disorder and epilepsy, and regularly fails to take her prescribed medication. As such, Defendant's mental and physical state make her a danger to the child, and her decisions regarding the child less than reasonable; and (e) Plaintiff has the facilities to provide for the care, comfort and control of the child, as well as the intention and desire to do so. WHEREFORE, Plaintiff requests that this Honorable Court grant the following relief: (a) Award Plaintiff full physical and sole legal custody of the child. Respectfully Submitted, Dated: ':J( 7f a 7 KOPE & ASSOCIATES, LLC B~~ esle ... . B am, Esq. VERIFICATION I, Frank Pretopapa, verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. s. 9 4904 relating to unsworn falsification to authorities. Dated: 3 -1-- 07 {~~ Frank Pretopapa, Plaintiff KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam((l2kopelaw.com Attorney for Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. FRANK PRETOPAPA, Plaintiff, BRANDY RITTLE, Defendant. CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this day of , 2007, in consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , Esquire, the conciliator, at Pennsylvania, on the day of , at o'clock m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Either party may bring the children who are the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Custody Conciliator . . YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 ;? F l' r ~ vol o<? Vl ("'- 0.() ~ -.J;> ~ @, ~ ~ r-..;) 0 c.;? -n ::::. -.... _!'::oo ;)0 , Cfj .........No ~F' ~ -- -- D. ') IAR08Z~ ~ fi KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY 1.0. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff FRANK PRETOPAPA, Plaintiff, VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. tJ7-j;JS'tf &;xi T~ BRANDY RITTLE, Defendant. CIVIL ACTION - LAW IN CUSTODY AND NOW, this <e-tA. ORDER day of ",~ , 2007, in consideration of the foregoing Emergency Petition for Special Relief filed by Frank Pretopapa, it is hereby ORDERED and DIRECTED that~ ~ 1"t-~~ ~ ~ ~I ...~.., fb. .I r 1'4'-"- '..., ~., ..:It 1..'o-oA~tNI. eo:. ~~ ..1 ~ ~ ~J~~~:O~'~~"'i1'G.i~~~J~~:;~'3 r..nk pr8t8t)8~, fjCr - ~I~~ . , I' .; ; p" ~ ~ . ~ r:QR~'" !:InQ. further _ ("\J;r1gr Qf tho r.nljrt. 2. Ell3Rsr RittlQ, R"lQtlxlgr ~Rg ni'f!i'Rd~Rt Ixlw..oin. !:Inrl/nr !:In~' thirn p;:lrtv who may be taking - .=-..0 nf thA r:hiln ;:It thic:. tirno. irnm~ni~tI:~l\I "wliRq'li.c:.h tho f"hiln tn Frank Pretopapa's care and _~litQd~' PQRdiRg ~ prQ RgariR~ "88R8i1iati8R (;'QRfgr9rf"0 !:Inn p 1I)<U~Qr Or'"'''''' h~, tpic- ("'"'U/i. .--tt. Bfa"!!)' f:liMle PA8~' RS'I'Q ~WJi8P1i88S 'Jieitsti8R ~Rlr ~~' :;il9rggm'iRt ~ tR9 Jiiil~i'Or p'ORc"ing. a ~"9 ~~AriR8 C8flC,;I;dlk'll eUllrC' Ijllce. , J. C8 :8 ~~d 8- ~VH LOOl Ab'V10t\lOH1GUd 3H1 :10 3C)L~!jO.{J911j KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY 1.0. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 IbeamCWkooelaw.com Attorney for Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O~- 1;L~9 C(J~L/~ CIVIL ACTION - LAW IN CUSTODY FRANK PRETOPAPA, Plaintiff, BRANDY RITTLE, Defendant. STIPULATION AND NOW, this 9th day of March, 2007, it is STIPULATED and AGREED by and between the parties, Frank Pretopapa ("Father") and Brandy Rittle ("Mother"), intending to be legally bound hereby, that an Order regarding the custody and visitation of their minor child Mason Pretopapa, born October 28, 2004 (hereinafter the "Child") shall be entered as follows: 1 . Legal Custody: It is the intention of the parties and the parties agree that they will have shared legal custody of the Child. The parties agree that major decisions concerning the Child, including, but not limited to, the Child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the Child's best interest. In the event that the parties are unable to come to agreement regarding a particular issue, that decision should be made by the 1 Father. Each party agrees not to impair the other party's rights to shared legal custody of the Child. Each party agrees not to attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning their Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions which must be made, the party having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or any and all other authorities and to have copies of any reports given to either party as a parent pursuant to 23 Pa.C.S.A. 95309. 2. Primary Physical Custody: Primary physical custody of the Child shall be with the Father. 3. Partial Physical Custody: Mother shall have partial physical custody and visitation of the Child by agreement of the parties. 4. Holidays: The parties agree to share and/or split physical custody of the Child on major holidays, including Christmas, New Years Day, Memorial Day, Fourth of July, Labor Day and Thanksgiving. Holidays will be split by agreement of the parties. 5. Transportation: The parties shall share responsibility for the transportation for the Child. In the absence of agreement, the party receiving custody shall pick up the Child from the other party's home. 2 6. Parents should provide one another with a phone number and address where the Child may be contacted when in the physical custody of the other, whenever reasonably possible. This principle applies to situations such as vacations and overnights with friends. Each parent should be promptly and politely responsive to the other parent's telephone calls. 7. During any period of custody or visitation the parties to this Order shall not possess or use any controlled substance, nor shall they consume alcoholic beverages to the point of intoxication, nor smoke cigarettes inside the residence or vehicle. The parties shall likewise assure, to the extent possible, that other household members and/or houseguests comply with this prohibition. 8. Telephone Contact: Each parent shall be entitled to reasonable telephone contact with the Child which shall not be excessive. 9. No Conflict Zone: Each parent agrees not to attempt to alienate the affections of the Child from the other and will make a special conscious effort not to do so. Both parents shall establish a no-conflict zone for their Child and refrain from and, to the extent possible, shall not permit third parties from making such comments in the presence of the Child whether the Child is sleeping or awake. Each parent shall speak respectfully of the other whether it is believed the other reciprocates or not. Each parental figure shall refer to the other by the appropriate role name such as Mom, Dad, your grandmother, etc. Each parent should agree to refrain from encouraging the Child to provide reports about the other parent. Communication should always take place directly between parents, without using the Child as an intermediary. 3 10. Applicable Laws: Any provision in this Agreement regarding child custody and visitation shall be governed and enforceable as set forth in the applicable Pennsylvania Rules of Civil Procedure, as well as any other remedies available at law or in equity. 11. Modification: The provision of this Paragraph shall be modified according to applicable law. 12. UCCJEA and PKPA: Should it become necessary for the parties to proceed in any court outside the Commonwealth of Pennsylvania or in any county outside the County of Cumberland to enforce any of the provisions of this Agreement, such enforcement shall be, at Father's option, in accordance with the provisions of the Uniform Child Custody Jurisdiction and Enforcement Act of Pennsylvania, 23 Pa.C.S.A. SS 5400-5482 ("UCCJEA") and the United States Parental Kidnapping Prevention Act, 28 U.S.C.A. S 1738A ("PKPA"). Should it become necessary for the Father to apply to any court for enforcement of the custody obligations provided for in this Agreement, the Mother hereby consents to the entry of any order required by any court or pursuant to the provisions of UCCJA and PKPA, and she will not oppose an application being brought pursuant to these statutes. 4 KOPE & ASSOCIATES 4660 Trindle Road, Suite 201 Camp Hill, PA 17102 Telephqtle (717) 761-7573 (....../J'" /J Ii .,..7 / Sworn to or affirmed and acknowledged before me by Brandy Rittle 0. on rfbv~ - I I 2007 LMNN M IENICM NoICIY "** ~ IOIOUQM MIFf" COUN1V Frank Pretopapa 138 Peach Lane Carlisle, PA 17013 ,~~ Plaintiff Brandy Rittle + I }CIo~ rY'ar/U 'OT Ha( r l~b()r6 ~ft \llO~ AJ.r0Rrl~ R~~ Defendant ~ 5 2 ::t.~ '1 .';;'~3& "', ;itri,lf,-i:, . ~;:::!'J~ 'r:.:.~"t" ;';<"'wi<>H(~ ~(jT~j"X* ",,-,;..' ~fllI.,: '. tH.:' --i"l'l;,: "'-> (=:'::1 t:'_,',:') -_.1 :~_~"'lt ::-::J ..r:.- -:-, '-...;"1 Ui ....~ . FRANK PRETOPAPA PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 07-1259 CIVIL ACTION LAW BRANDY RITTLE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, March 12,2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, April 13, 2007 at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearine;. FOR THE COURT. By: Isl John.f. Mangan, Jr., Esq. Vi Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3 166 'ff~~~~~ (O-~/F' - * ::z ~ ~ CC7-N_~ ~~ :2~~;hp (O~/-E' - ;~J/',JnC) ~1 I \P:HI [ODl ! ~ :21 !:d '{ (J,,, 3Hl.:lO KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-I::lS9 FRANK PRETOPAPA, Plaintiff, BRANDY RITTLE, Defendant. : CIVIL ACTION - LAW : IN CUSTODY ACCEPTANCE OF SERVICE I, Brandy Rittle, Defendant in the above-captioned matter, hereby accept service of the Complaint in Custody. I, Brandy Rittle, Defendant in the above-captioned matter, hereby accept service of the Emergency Petition for Special Relief and of the Order scheduling hearing. Date:3/q Itn S. l n Jttff".\.-t --' kili Q. Brandy Rittleo r--.:> c::> = --' ~ "',"'-.p :;;Q o -/1 ~-n rl1F -aQ:l ~JV ::;, ~~", r ~ -., ~';-; ~~ ~:.! (:-S 9\cn ~.o :...:.: ... -0 _;,-,10 ~ en N FRANK PRETOPAPA, Plaintiff, vs. BRANDY RITTLE, Defendant. f!;J MAR 1 5 70071 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-1259 : CIVIL ACTION - LAW : IN CUSTODY ORDER AND NOW, this 2b ~ day of ~ 2007, the attached Stipulation signed by the above captioned parties is approved and entered as an Order of the Court. J. 6 VI NVA1ASNN3d )JJ~nC(' Oi--J\11H3BV'lna 03 :E Wd Ol HVW iDOl AlNIONOHIOOd 3H1 :K) rol;Ho-o318